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  • 4.

    Potential favorable information;

  • 5.

    The names and addresses of all prosecution witnesses, their prior statements, and criminal

record, if any;

  • 6.

    Any other information that may be used to impeach the testimony of prosecution witnesses;

  • 7.

    All oral or written statements by the client, and the details of the circumstances under which the statements were made;

8. The prior criminal record of the client and any evidence of other misconduct that the government may intend to use against the client;

  • 9.

    Statements made by co-defendants;

  • 10.

    Statements made by other potential witnesses;

  • 11.

    All official reports by all law enforcement and other agencies involved in the case, e.g.,

police, arson, hospital, results of any scientific test(s);

  • 12.

    All records of evidence collected and retained by law enforcement;

  • 13.

    All video/audio recordings or photographs relevant to the case, as well as all recordings of transmissions by law enforcement officers, including radio and computer transmissions;

  • 14.

    All books, papers, documents, tangible objects, buildings or places, or copies, descriptions, or other representations or portions thereof, relevant to the case;

  • 15.

    All results or reports of relevant physical or mental examinations, and of scientific tests or experiments, or copies thereof; and

    • 16.

      A written summary of any expert testimony the prosecution intends to use in its case-in- chief at trial.

  • C.

    If counsel has made formal discovery demands, counsel should seek prompt compliance and sanctions for failure to comply.

D. Counsel should timely comply with all of the requirements governing disclosure of evidence by the client and notice of defenses and expert witnesses. Counsel should be aware of the possible sanctions for failure to comply with those requirements.

12

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